SURJEET SINGH,SIRSA vs. PCIT, ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

271-276 of JPB). iii) ITA No. 1393/D/2017 Dated: 16.04.2021 Paramjeeet Singh Vs ACIT. (Page 277-280 of JPB). iv) ITA N. 5084/D/2019 Dated: 06.07.2022 Girish Kumar vs. ITO (Page 343-348 of JPB). v) ITA No. 1418/D/2023 Dated 21.09.2022 Kamla Devi vs. ITO (Page 349-355 of JPB). vi) ITA No. 1539/D/2020 Dated 17.03.2023 ITO vs. Hari Singh Saini

SH. KASHMIR SINGH SANDHA,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

271-276 of JPB). iii) ITA No. 1393/D/2017 Dated: 16.04.2021 Paramjeeet Singh Vs ACIT. (Page 277-280 of JPB). iv) ITA N. 5084/D/2019 Dated: 06.07.2022 Girish Kumar vs. ITO (Page 343-348 of JPB). v) ITA No. 1418/D/2023 Dated 21.09.2022 Kamla Devi vs. ITO (Page 349-355 of JPB). vi) ITA No. 1539/D/2020 Dated 17.03.2023 ITO vs. Hari Singh Saini

M/S GANESH DASS HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

271-276 of JPB). iii) ITA No. 1393/D/2017 Dated: 16.04.2021 Paramjeeet Singh Vs ACIT. (Page 277-280 of JPB). iv) ITA N. 5084/D/2019 Dated: 06.07.2022 Girish Kumar vs. ITO (Page 343-348 of JPB). v) ITA No. 1418/D/2023 Dated 21.09.2022 Kamla Devi vs. ITO (Page 349-355 of JPB). vi) ITA No. 1539/D/2020 Dated 17.03.2023 ITO vs. Hari Singh Saini

DHUNI CHAND HUF,SIRSA vs. PCIT, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

271-276 of JPB). iii) ITA No. 1393/D/2017 Dated: 16.04.2021 Paramjeeet Singh Vs ACIT. (Page 277-280 of JPB). iv) ITA N. 5084/D/2019 Dated: 06.07.2022 Girish Kumar vs. ITO (Page 343-348 of JPB). v) ITA No. 1418/D/2023 Dated 21.09.2022 Kamla Devi vs. ITO (Page 349-355 of JPB). vi) ITA No. 1539/D/2020 Dated 17.03.2023 ITO vs. Hari Singh Saini

SH. RANDHIR SINGH,SIRSA vs. PCIT ROHTAK, ROHTAK

In the result, all the above appeals filed by the respective assessee’s are dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

271-276 of JPB). iii) ITA No. 1393/D/2017 Dated: 16.04.2021 Paramjeeet Singh Vs ACIT. (Page 277-280 of JPB). iv) ITA N. 5084/D/2019 Dated: 06.07.2022 Girish Kumar vs. ITO (Page 343-348 of JPB). v) ITA No. 1418/D/2023 Dated 21.09.2022 Kamla Devi vs. ITO (Page 349-355 of JPB). vi) ITA No. 1539/D/2020 Dated 17.03.2023 ITO vs. Hari Singh Saini

DCIT, C-1(1), CHANDIGARH vs. CHANDIGARH HOUSING BOARD, CHANDIGARH

In the result, the appeals filed by the revenue for assessment year 2010-11 and 2011-12 are dismissed

penalty proceedings by following the order of ITA Nos.1310 & 1311/Chd/2019 A.Ys .2010-11 & 2011-12 Page 3 of 7 the ITAT rendered in the assessee’s own case for the assessment year2007-08. 2. The Ld. Pr.CIT, Chandigarh, by exercising jurisdiction u/s 263 of the Act, revised the order passed by the AO u/s 271

DCIT, CC-I, CHANDIGARH , CHANDIGARH vs. VALCO INDUSTRIES LTD., , CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: The Hon'Ble Punjab & Haryana High Court? Ii) Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Is Right Holding Such Consequential Order As Void An Initio Ignoring The Facts That Order Passed By Ld. Pcit (Central), Gurugram U/S 263 Has Not Attained Its Finality? Iii) Whether On The Facts & In Circumstances Of The Case & In Law, The Ld. Cit(A) Was Right In Holding That Consequential Order Passed U/S 147 R.W.S. 263 Of The Act As Void As Initio Without Giving Any Liberty To The Revenue To Revive The Proceedings Consequent To Any Directions Or Order

penalty proceedings u/s 271(l)(c) of the I.T. Act, 1961 is being initiated. Subject to above income of the assessee is computed as under:- Last Assessed Income as per order 4,76,40,025/- dated 10.03.2016 Addition as discussed above 4,11,52,839/- Total Income 8,87,92,864/- Income Rounded off u/s 288A

DCIT, CHANDIGARH vs. CHANDIGARH HOUSING BOARD, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

revise his return for the incumbent assessment year i.e. 2012-13? 3. Whether on the facts and in the circumstances of the case and in law, the CIT(A) has erred in setting aside the penalty on account of disallowance of interest expenditure by relying upon the 'record of discussions' which were specific to the assessment year

SHRI BALBIR SINGH VERMA,SHIMLA vs. PR.CIT, SHIMLA

In the result, appeal of the Assessee is allowed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

u/s 263 of the Income Tax Act, 1961 by the Learned Principal Commissioner of Income Tax is bad in law in as much as the date of order as per the impugned order is 19.03.2020 and which has been signed without mentioning of a DIN. As per the separate order, the Learned Principal Commissioner of Income Tax has mentioned

M/S SINGH CONSTRUCTION CO.,PATIALA vs. ACIT, CIRCLE, PATIAL

In the result, the appeal of the assessee is dismissed

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

Penalty proceedings u/s 271(1)(c) of the Income Tax Act, 1961 are initiated for concealment or furnishing inaccurate particulars of income.” 10. Against the said findings and the order of the AO, the assessee moved in appeal before the Ld. CIT(A) wherein the Ld. CIT(A) directed the AO to apply net profit of 5.74% which

DINESH VERMA,MANALI, HIMACHAL PRADESH vs. ITO, ITO WARD KULLU

In the result, appeal filed by the Assessee is dismissed

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

u/s 270A of the Act after following due procedure laid down and to take consequential action. 5. Aggrieved, the assessee has preferred the present appeal before the Tribunal. 6. During the course of hearing the Ld. AR submitted that the Assessing Officer had examined the matter and therefore the revision under section 263 was invalid. It was contended that

MRS.UMA RANI PRABHKAR,SHIMLA vs. DCIT,CIRCLE SHIMLA, SHIMLA

In the result, appeal of the assessee is dismissed

271(l)(c) of the Act, thereby imposing a penalty of Rs. 3,48,590/- . Against the said order dated 29/08/2016, an appeal was filed on dated 28/09/2016. 2 ITA 1143/Chd/2019_ Mrs. Uma Rani Prabhakar Vs DCIT 3. That the case of the applicant was opened in revision u/s 263

OSHO FORGE LTD.,LUDHIANA vs. DCIT, LUDHIANA

Appeal of the Assessee is allowed and penalty is deleted

Bench: Shri Rajpal Yaday & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 523/Chd/2024 "नधा"रण वष" / Assessment Year : 2007-08 Osho Forge Ltd., Vs. Dcit, बनाम D-42, Phase V, Circle 1, Focal Point, Ludhiana, Ludhiana Punjab 141010 "थायी लेखा सं./Pan No: Aaaco3362I अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Sarabjit Garg, Ca राज"व क" ओर से/ Revenue By : Sh. Ved Parkash Kalia, Jcit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27.11.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 02.12.2024

revised by CIT revisional order u/s 263. We are of the view that though in the fresh assessment order penalty has been initiated on this item also but this is not an item for which the penalty is to be visited upon the Assessee because it was an estimated addition made by the A.O. He has not pinpointed

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

263(revision of orders) of the Act. The Hon’ble High Court has further observed that the words “assess” or “re-assess” have been used at more than one place in the section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of abated proceedings

SH. KRISHAN KUMAR GOYAL,CHANDIGARH vs. DCIT, CC-1, CHANDIGARH

In the result, both the appeals of the assessee stand allowed

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकर अपील सं./ Ita No. 226/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent & आयकर अपील सं./ Ita No. 456/Chd/2019 "नधा"रण वष" / Assessment Year : 2007-08 The Dcit, Shri Krishan Kumar Goyal, बनाम Central Circle-1, Prop Sagar Enterprise, Chandigarh Scf 153, Sector 26, Grain Market, Chandigarh "थायी लेखा सं./Pan No. Agipk9063H अपीलाथ"/Appellant ""यथ"/Respondent

263(revision of orders) of the Act. The Hon’ble High Court has further observed that the words “assess” or “re-assess” have been used at more than one place in the section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of abated proceedings

M/S SATWANT AGRO ENGINEERS,BHAWANIGARH vs. DCIT, CENTRAL CIRCLE, PATIALA

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

revise not only the ultimate computation arrived at but every process which lead to the ultimate computation or assessment". The Hon'ble Kerala High Court in the case of V. Subramonia Aiyr vs. CIT [1978] 113 ITR 685 held that "the power conferred on Appellate Authority by Section 2 which is exercised in accordance with procedure with Section 250 indicate